[HEADLINE]

This Privacy Policy (“Privacy Policy”), applies to all Crock A Doodle customers and users of the website found at crockadoodle.com (the “Site”).  Crock A Doodle and crockadoodle.com are business names used by Crock A Doodle Inc., an Ontario, Canada corporation (“Crock A Doodle”, “we”, “us”, “our”) and its franchisees under licence.  We grant franchise rights in a paint your own pottery program to franchisees who offer pottery-painting activities, parties and programs in a contemporary retail studio format and via events throughout their communities.  We license the Crock A Doodle® trademarks and associated logos to our franchisees. This Privacy Policy sets out the terms upon which we will collect, use and disclose your personal information in connection with your use of the Site, your purchase of Crock A Doodle products and services from us and your participation in our promotions, contests and programs. We recognize the importance of protecting the privacy of Crock A Doodle customers and users of the Site and have created this Privacy Policy to demonstrate our commitment to privacy.  Please be aware we may make changes to this Privacy Policy from time to time, and all such changes shall be immediately applicable. We will endeavor to notify you of any material changes to this Privacy Policy. Your continued use of our Site following the posting of changes to this Privacy Policy will mean you accept those changes.  If you do not agree with this Privacy Policy then your only recourse is to stop using the Site.

1. What Information is Collected

Crock A Doodle may collect and use Personal Information from Crock A Doodle customers and users of the Site.  “Personal information” means information about an identifiable individual as that term is used and defined in the Privacy Legislation, including without limitation, name, address, postal code, phone number, email address, age, gender, likeness, consumer preferences, income range, payment information. “Privacy Legislation” means applicable privacy legislation in Canada including without limitation, the Personal Information Protection Act (Alberta), Personal Information Protection Act (B.C.), Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and the Loi sur la protection des renseignements personnels dans le secteur privé (Quebec).

2. Purposes for Collection

Crock A Doodle may use your information for various purposes.  For example, Crock A Doodle may collect, use and disclose personal information to communicate with you about our products and services; to solicit your business and inform you about our products, services, programs (including loyalty programs), promotions and contests; to maintain a record of customers; to process payments; to provide delivery services; to provide customer service; to analyze your data and usage patterns; to improve our service offerings and to improve your experience with our Site. Except as otherwise described, we will not rent, sell, or otherwise distribute your Personal Information without your permission.   Your voluntary use of our Site and your voluntary disclosure of your Personal Information to us for the purposes described above, constitute your express consent to such uses.

3. Consent

Crock A Doodle will only collect, use and disclose your Personal Information with your knowledge and consent, except where permitted or as required by law. Except as otherwise set out herein, Crock A Doodle will not rent, sell, or otherwise distribute your Personal Information without your permission. Your voluntary use of our services and your voluntary disclosure of your Personal Information to us for the purposes described herein constitute your express consent to such uses.  We will not without your express consent make use of your information for any other purposes except as may be described herein and as may be reasonably anticipated by you having regard to the nature of our services. We will seek to provide you with the option to prevent future secondary use of your information by “opting out” when Crock A Doodle collects your information or by contacting us.

4. User Profile and Usage Behaviour Information

In addition, Crock A Doodle may collect and store Personal Information to create and generate a user profile and to track usage behaviour in order to operate the Site and enable you to have a personalized experience on the Site.  Such information may include, without limitation, a user name, a password, password reminder questions and answers, interests, communication preferences, correspondence that you send to Crock A Doodle, and navigation data such as web pages and advertisements you view and links you click on within the Site. Crock A Doodle may also collect and analyze aggregate data assembled from information collected via the Site.  Aggregate information is collected in order to better understand the demographics and usage patterns of all users of the Site, so that Crock A Doodle can provide the highest level of service to its customers.  Such aggregate data is not generally personally identifiable or linked to a specific user. Crock A Doodle servers may automatically collect certain technical information about your use of the Site, including, without limitation, your browser type, your operating system, unique identifiers, mobile device identification numbers, your bandwidth speed, and information collected through cookies, web beacons, and other technologies.  This may also include collecting and logging IP addresses.  Crock A Doodle may collect IP addresses for system administration, security and statistical analysis.  An IP address is a number that is assigned to a computer whenever it is communicating over the Internet.  Crock A Doodle and its internet service provider may log these IP addresses and analyze them to understand where requests originate.

5. How the Information Is Disclosed to Third Parties

In certain circumstances, Crock A Doodle may share your information with third parties who provide services to Crock A Doodle in order to enable Crock A Doodle to offer products and services to its customers, operate the Site or to enhance the Site.  Examples of such third party service providers could include payment processors, delivery services and third party marketing and promotional agencies. Co-Branded Partners are third parties with whom the Site may jointly offer a service or feature. You can tell when you are accessing a service offered by a Co-Branded Partner because the Co-Branded Partner’s name will be featured prominently. You may be asked to provide information about yourself to register for a service offered by a Co-Branded Partner. In doing so, you may be providing your information to both Crock A Doodle and the Co-Branded Partner, or Crock A Doodle may share your information with the Co-Branded Partner. Please note that the Co-Branded Partner may have terms of use and privacy policies and practices which differ from ours.  Such Co-Branded Partner’s privacy policy may apply to its use of your information. Crock A Doodle may disclose information about its users, including contact information, to respond to subpoenas, warrants, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations.   Please note we will not, unless required by law, provide you with notice prior to disclosure in such cases. Crock A Doodle or its affiliates may assign, sell, license or transfer any information, including Personal Information, that you have provided to Crock A Doodle to those third parties directly involved in any transfer or disposition of the assets. We may disclose information to protect and defend our legal rights, interests, and safety of our employees, agents, franchisees and contractors; to protect the rights, safety and security of users of the Site and members of the public; and as otherwise disclosed in this Privacy Policy. Although in many cases the activities of our third party providers appear to be coming from our Site, they may actually be coming directly from such third parties, or from our franchisees.  During your visit to our Site you may link to or view as part of a frame on our page content that is created or hosted by a third party or one of our franchisees.  Third parties accessible through our Site (including our franchisees) have their own terms of use and privacy policies. We are not responsible for their actions, privacy, security or content. If you are asked to provide Personal Information to a third party (including any of our franchisees), we encourage you carefully to review their Privacy Policy and terms of use before disclosing your information. We will use reasonable efforts, including contractual means where appropriate, to ensure that any third party or service provider to whom we transfer Personal Information maintain privacy standards equal to or better than our own.  However we have no direct control over the use of this information by these third parties.   If you have concerns about our disclosure practices and the identities of any third parties to whom we may have disclosed your Personal Information, please contact our Privacy Officer at the address specified above.

6. Limiting Collection

We will only collect Personal Information for the purposes and uses described above and herein as may be reasonably anticipated by you having regard to the nature of our products, Site and services.  Except as set out above and herein, we will not without your consent use your Personal Information for any other purposes.  We will endeavor to inform you of additional purposes which are not contemplated above and if necessary we will seek your consent should we desire to collect, use or disclose your Personal Information for such additional purposes or uses. We will keep your Personal Information for only as long as reasonably necessary to fulfill the purpose for which it was disclosed.

7. Cookies and Web Beacons

Crock A Doodle may receive information from third parties about you and your activities on other sites for the purpose of serving relevant advertisements to you on the Site.  In addition, Crock A Doodle may use cookies, web beacons, and other technologies to collect information about content you view on business partner web sites to customize advertising on the Site.  Crock A Doodle may use web beacons to improve your experience on the Site, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that the Site can deliver relevant content. Crock A Doodle’s web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).  The Site also may include third-party web beacons so that these third parties may receive auditing, research, and reporting information about advertisements viewed on the Site.  By contacting Crock A Doodle, you may choose to opt out of Crock A Doodle’s use of data that is collected about your visits to its business partners’ sites to customize advertising that the Site serves. “Cookies” are small computer files that we transfer to your computer’s hard drive.  Crock A Doodle may use cookies to monitor how you are using our websites, for what purposes, how often you visit our websites and how for how long.   Crock A Doodle uses temporary cookies to keep a session open after a user logs in. These cookies do not contain any Personal Information and will expire automatically after the session is finished. Most browsers are set to accept cookies.   You can manually set your browser to refuse cookies and this may interfere with your access to certain of our services,

8. Mobile Devices

Certain mobile devices contain unique identifiers that can be used, for example, to identify the physical location of such devices. Mobile devices also typically transmit caller ID data when used to transmit a telephone call or text message. The Site may collect, use, transmit, process and maintain unique identifiers, caller ID data, location-based data, and similar information when you rely on mobile devices, including to provide the services you request and improve your experience on the Site. The Site also may require collection of your mobile phone number in order for you to participate in certain services or features and that number may be associated with such information.

9. Privacy Protections for Children

No part of the Site is designed or directed to children.  To provide Personal Information through the Site you must be at least eighteen (18) years of age.  Therefore, Crock A Doodle does not knowingly collect Personal Information from any minor or other person under age thirteen (13).  If you believe that we have any information respecting anyone under the age of 13, please contact our Privacy Officer.

10. Opt-Out

If you object to the disclosure or use of your Personal Information by Crock A Doodle you may contact Crock A Doodle.  However, you acknowledge that if you do not allow Crock A Doodle to utilize your information, then Crock A Doodle may not be able to provide certain information and services to you.

11. Accuracy / Correcting and Updating your Information

We will accurately maintain your Personal Information as it was provided to us, for the identified purposes for which it was collected.  You must provide us with correct information and update this information from time to time.

12. Security

We take reasonable precautions to maintain the security and accuracy of Personal Information we collect, including limiting the number of people who have access to our servers, as well as using standard security systems and password protections that prevent unauthorized access. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting sensitive Personal Information such as credit card data. We cannot guarantee the security of any information you disclose online and you do so at your own risk.

13. Openness

We reserve the right to amend or update this Privacy Policy.  If any changes materially affect you, we will notify you.  You may access an up to date version of this Privacy Policy at any time by emailing us or by clicking on the Privacy Policy links on the Site.

14. Individual Access

Except as otherwise required by law you have access to your Personal Information maintained by us.  You have the right to challenge the accuracy and completeness of your information and have it amended if appropriate.  If you wish to update or delete your Personal Information, or opt out of any particular use, send our Privacy Officer a written request.

15. Governing Law and Hierarchy

This privacy policy agreement will be governed by the laws of the Province of Ontario, Canada without regard to any applicable conflicts of laws provisions as though all transactions with you using our system and services were performed physically within the Province of Ontario, Canada.

16. Language

You and we expressly acknowledge and agree that this Privacy Policy and all notices relating hereto be expressed in the English language only.   Il est expressément constaté et convenu que cette entente et tous les avis s’y rapportant soient redigés en anglais.

17. Individual Access

Subject to exceptions as permitted by law and subject to your written request, Crock A Doodle will inform you of the existence, use and disclosure of your Personal Information and give you access to that information. You have the right to challenge the accuracy and completeness of your information and have it amended as appropriate.  If you wish to change your Personal Information, opt out of any particular use or program, or request the deletion of all or any part of your Personal Information held by us, send us an email request at headoffice@crockadoodle.com.

18. How to Contact Crock A Doodle

If you have any questions, comments or complaints about this privacy policy, the practices of Crock A Doodle, or your dealings with this Site, you may contact our Privacy Officer via the contact information described below. 299 Wayne Gretzky Parkway Brantford, Ontario, Canada headoffice@crockadoodle.com